[arin-ppml] Draft Policy ARIN-2021-1: ASN Clarifications to Sections 2, 8 and 10

[Martin Hannigan]

Just waking up here with regards to the Section 10 change.

While the section 10 changes are subtle they are also problematic. I
suggest abandoning the Section 10 change. It is not worth it.  Nor is it
necessary. And it may even be undesirable.

Nowhere in the NRPM s the term ASN defined except in Section 10. When you
string it together such as "Autonomous System Number (ASN)" you imply that
you are creating a precise meaning. It is in Section 10. It has global
implications. The precise meaning was agreed to by ALL FIVE RIR's. If we
make this change, we make it imprecise. While there may be contractual
language elsewhere that define this term e.g. PTI agreement, conflict
causes confusion. And considering its a global policy change, do we want
that? It would require a round of global policy ratification in each RIR.

There is a better issue to resolve in Section 5 which doesn't involve
global policy. "Autonomous System Numbers (AS Numbers)". I would instead
change that to ASN or remove it and let the Section 10 term work backwards.
That's sort of a hack but I think it works at least from the POV of a
defined term. If we don't care about nerd-legalese then why not just ignore
them both?

I have two suggestions:

The first is ever embed a global policy change in another policy. In fact,
one rule change, one policy as a standard might be nice. The second is
tactical. If we do feel like we want to change the defined term in Section
10, split it out of this proposal and into its own. It will make life
simpler, although I doubt it will avoid a global goat rodeo asking "when is
a change a change".

Not in favor of this proposal as it stands at this point. Probably
should've noticed the section 10 item earlier. It is what it is. The
changes to the non global stuff are fine. The change to the global item may
be fine, but together they are not fine.

Warm regards,


-M<




On Tue, Mar 9, 2021 at 9:46 PM Chris Woodfield <chris at semihuman.com> wrote:

> Reading these changes, the majority of these proposed updates appear
> strictly editorial, but a few appear to at least have the potential to have
> an effect on policy, however subtle, as references to ASNs are being added
> in a few places where it wasn’t before, replacing the term “IPv4 address
> resources” had been used prior - a term could be interpreted as to *not*
> include ASNs.
>
> That said, these changes appear to be a positive clarification of the
> existing policy, and as such, I support as written.
>
> Thanks,
>
> -Chris
>
> On Mar 9, 2021, at 12:45 PM, ARIN <info at arin.net> wrote:
>
> On 18 February 2021, the ARIN Advisory Council (AC) accepted
> "ARIN-prop-296: ASN Clarifications to Sections 2, 8 and 10" as a Draft
> Policy.
>
> Draft Policy ARIN-2021-1 is below and can be found at:
>
> https://www.arin.net/participate/policy/drafts/2021_1/
>
> You are encouraged to discuss all Draft Policies on PPML. The AC will
> evaluate the discussion in order to assess the conformance of this draft
> policy with ARIN's Principles of Internet number resource policy as stated
> in the Policy Development Process (PDP). Specifically, these principles are:
>
> * Enabling Fair and Impartial Number Resource Administration
> * Technically Sound
> * Supported by the Community
>
> The PDP can be found at:
> https://www.arin.net/participate/policy/pdp/
>
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/participate/policy/drafts/
>
> Regards,
>
> Sean Hopkins
> Senior Policy Analyst
> American Registry for Internet Numbers (ARIN)
>
>
>
> Draft Policy ARIN-2021-1: ASN Clarifications to Sections 2, 8 and 10
>
> Problem Statement:
>
> The community has raised concerns that the current language in Section 8
> is not clear regarding ASN-only transactions. There are also some language
> and reference inconsistancies which should be addressed while adjusting
> Section 8 and concordant adjustments to Sections 2 and 10.
>
> Policy Statement:
>
> Add a definition for ASN in Section 2:
>
> Section 2.X Autonomous System Number (ASN)
>
> An Autonomous System Number (ASN) is a unique identifier which represents
> a collection of network resources operated under a common routing policy
> administration, known as an autonomous system.
>
> In Section 8.2:
>
> Replace
>
> “The Internet number resources being transferred as part of an 8.2
> transfer will not be subject to a needs-based assessment during the process
> of the 8.2 transfer.”
>
> with
>
> “The Internet number resources being transferred as part of a transfer
> under section 8.2 will not be subject to a needs-based assessment during
> the process of the transfer.”
>
> Replace
>
> “The recipient must provide evidence that they have acquired the assets
> that use the resources to be transferred from the current registrant.”
>
> with
>
> “The recipient must provide evidence that it has acquired the assets that
> use the resources to be transferred from the current registrant.”
>
> Replace
>
> “The recipient must show that they have acquired the entire entity which
> is the current registrant.”
>
> with
>
> “The recipient must show that it has acquired the entire entity which is
> the current registrant.”
>
> Replace
>
> “An organization which serves as the source of an 8.2 IPv4 transfer will
> not be allowed to apply for IPv4 address space under section 4.1.8 ARIN
> Waitlist for a period of 36 months following said transfer unless the
> recipient organization remains a subsidiary, parent company, or under
> common ownership with the source organization.”
>
> with
>
> “An organization which serves as the source of an IPv4 transfer under
> section 8.2 will not be allowed to apply for IPv4 address space under
> section 4.1.8 ARIN Waitlist for a period of 36 months following said
> transfer unless the recipient organization remains a subsidiary, parent
> company, or under common ownership with the source organization.”
>
> In Section 8.3:
>
> Replace
>
> “In addition to transfers under section 8.2, IPv4 numbers resources and
> ASNs may be transferred according to the following conditions.”
>
> with
>
> “In addition to transfers under section 8.2, IPv4 address and/or ASN
> resources may be transferred according to the following conditions.”
>
> Replace
>
> “The source entity must be the current registered holder of the IPv4
> address resources, and not be involved in any dispute as to the status of
> those resources.”
>
> with
>
> “The source entity must be the current registered holder of the IPv4
> address and/or ASN resources, and not be involved in any dispute as to the
> status of those resources.”
>
> Replace
>
> “Number resources received as the result of an 8.2 transfer are out of
> scope for the purposes of this restriction.”
>
> with
>
> “Number resources received as the result of a transfer under section 8.2
> are out of scope for the purposes of this restriction.”
>
> In Section 8.4:
>
> Replace
>
> “Inter-regional transfers of IPv4 number resources and ASNs may take place
> only via RIRs who agree to the transfer and share reciprocal, compatible
> needs-based policies.”
>
> with
>
> “Inter-regional transfers of IPv4 addresses and/or ASN resources may take
> place only via RIRs who agree to the transfer and share reciprocal,
> compatible needs-based policies.”
>
> Replace
>
> “The source entity must be the current rights holder of the IPv4 address
> resources recognized by the RIR responsible for the resources, and not be
> involved in any dispute as to the status of those resources.”
>
> with
>
> “The source entity must be the current rights holder of the IPv4 address
> and/or ASN resources recognized by the RIR responsible for the resources,
> and not be involved in any dispute as to the status of those resources.”
>
> Replace
>
> “Source entities within the ARIN region must not have received a transfer,
> allocation, or assignment of IPv4 number resources from ARIN for the 12
> months prior to the approval of a transfer request, unless either the
> source or recipient entity owns or controls the other, or both are under
> common ownership or control. Number resources received as the result of an
> 8.2 transfer are out of scope for the purposes of this restriction.”
>
> with
>
> “Source entities within the ARIN region must not have received a transfer,
> allocation, or assignment of IPv4 addresses from ARIN for the 12 months
> prior to the approval of a transfer request, unless either the source or
> recipient entity owns or controls the other, or both are under common
> ownership or control. Number resources received as the result of a section
> 8.2 transfer are out of scope for the purposes of this restriction.”
>
> Add a space between “Section” and “4.4” in the fourth bullet under
> “Conditions on source of the transfer”
>
> In Section 8.5.6:
>
> Replace
>
> “Organizations with direct assignments or allocations from ARIN must have
> efficiently utilized at least 50% of their cumulative IPv4 address blocks
> in order to receive additional space. This includes all space reassigned to
> their customers.”
>
> with
>
> “Organizations with direct assignments or allocations from ARIN must have
> efficiently utilized at least 50% of their cumulative IPv4 address blocks
> in order to receive additional IPv4 space. This includes all IPv4 space
> reassigned to their customers.”
>
> In Section 8.5.7:
>
> Replace
>
> “In lieu of 8.5.5 and 8.5.6, organizations may qualify for additional IPv4
> address blocks by demonstrating 80% utilization of their currently
> allocated space.”
>
> with
>
> “In lieu of the requirements in sections 8.5.5 and 8.5.6, organizations
> may qualify for additional IPv4 address blocks by demonstrating 80%
> utilization of their currently allocated space.”
>
> Replace
>
> “An organization may qualify via 8.5.7 for a total of a /16 equivalent in
> any 6 month period.”
>
> with
>
> “An organization may qualify via section 8.5.7 for a total of a /16
> equivalent in any 6 month period.”
>
> In Section 10.3:
>
> Replace
>
> “This document describes the policy governing the allocation of Autonomous
> System Numbers (ASNs) from the IANA to the Regional Internet Registries
> (RIRs).”
>
> with
>
> “This document describes the policy governing the allocation of ASNs from
> the IANA to the Regional Internet Registries (RIRs).”
>
> Timetable for implementation: Immediate.
>
> Anything else:
>
> This proposal is intended to be purely editorial in nature
>
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